IL.LINO1S POLLUTION CONTROL BOARI)
NOTICE OF FILING
II,I,IIYOIS POLJ,UTION CONTROL BOARD
PARTS 810 and 811
The current estimated annual cost for leachate monitoring is $7,200.
ECONOMIC EFFECT
811.315(e)(l)(G)(ii) -Groundwater standard
81 1.318(e)(6)(E) -Specific Conductance
The estimated cost for the proposed semi-annual sampling requirement is $15,000
ECONOMlC EFFECT
Therefore the current annual cost is estimated at $25,000
Therefore the proposed annual cost is estimated at $25,000
$2,153,000.
BEFORE THE ILI,INOIS POLLUTION CONTROL BOARD
2. Proposed (New) section 811.320(b)(l)

IL.LINO1S POLLUTION CONTROL BOARI)

In the Matter

of:

I'R(lPOS1-:D AMI',"\DMENTS TO

SOI,ID WASTE 1)ISPOSAL:

GENERAL PROVISIONS

35

Ill. Atlm. Code 810; and,

STAUDARDS FOR NEW SOLID

W 4STE LANDFILLS

LANDFILLS

35 Ill Adm Code 81 1

)

R 07-008

(Rulemaking

Land)

NOTICE OF FILING

TO See attached Service L~st

PLEASE TAKE NOTICE that on February 15, 2007, I caused to be filed eleclromcally

with the Office of the Clcl-k of the Pollut~o~i

Control Board, on behalf of the Nat~onal Solld

Wastes Vdnagemeiit Assoc~at~o~i

the attached Errata Sheet #3, the "Test~mony of Toni H~lbelt

Concertltng an Analysis of Econoln~c Effect or the Proposed Regulatory Amendments to 35

Illinois Administrative Code Parts 810 and 811; and a Notice of Filing in the above matter,

copies of which are

heicby served upon you

...-

-,.&:

z...<,~<,~

,-,?

-*-y 

,///77-.-".'  

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By:

. y'

<-I

.>

~harles .i.%ol-thrup

Sorliiig, Northnip, Hanna,

Cullen

Cocl?ran, I.td.

Cl~aries J. Northrup, of Counsel

Suite

SO0

Illinois B~~ilding

P.O. Box 5131

Springfield, IL 62705

Teleplione: 217.544.1 144

Fax: 217.522.3

173

E-Mail:

~riiir1i~.~:?&c'so1~~~!gi3!?,~~n_? 

{SO534234 I 28i482007 C'IK t31,F)

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II,I,IIYOIS POLJ,UTION CONTROL BOARD

lo the Matter

of:

PKOI'OSI<L) AMIiKDMEKTS TO

SOL-ID WASTE L>ISPOSAL:

(;EKEKAl. PROVISIONS

R 07-008

35 Ill. ildnl. Code 8 10; and,

(Rulemalting

I.,and)

STAVDARDS FOKNEW SOLID

WASTE L4NDFlLLS

LANI)FII.I,S 35 Ill. Adni. Code 8 1 I

?RE-FILED TESTIMONY OF NSWMA WITNESS THOMAS A. HILBERT

CON( ERNING AN ANA1,YSIS OF ECONOMIC EFFECT OF THE PROPOSED

RE(;UI, .\TORY AMENDMENTS TO 35 ILLINOIS ADMINIS'I'RATIVE CODE

PARTS

810 and 811

My name is Thomas Hilbert and as the Board knows form my previous testimony,

I have been involved in this iulcmaking as a represeutative of the NSWMA for several

years. In

illis testimony 1 would simply like to present an economic analysis of the

possible effect of the proposed

rule anlendments. It is apparent from the analysis that the

proposed

amendmeisis will rcsult in some cost savings to the regulated community, but I

want to enrphasize that that is not the driving force behind these proposals. The cost

savings are a secondary result of the

NSWMA's desire to create a better enviroilmental

moiiitoring system that will not be burdened with focusing resources on studying

statistical or

sainpliiig artifacts. The overall estimated cost savings are an insignificant

portio~i of actual landfill operation costs. The proposed ainendments are motivated first

anti foremost by a desire to address advances and greater knowledge and experience in

the filed; advances and ltnowledge which we believe will result in better landfill

managen~cnt and oversight as well as enviromnental proteclioii.

In conducting this econoinic analysis, basic assumptions used to analyze the

potential economic effects of the proposal upon

owners and operators of Municipal Solid

Waste

Lanclfills (MSWLF) are as follows:

Each facility has a minimum of 20 groundwater monitoring wells and 4

leachate monitoring locations. Current routine groundwater monitoring

consists of

13 parameters that require laboratory analysis and 5 field

pariimeters. Routine leachate monitoring consists of 26 parameters that

reqliire laboratory analysis and 3 iield parameters.

7 here are 51 dctive MSWLF in Illinois

The

econolnic effect upon the Illinois Environmental Protection Agency and local

regulatory authorities are

not addressed ill this analysis.

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'This revie\\ presents a detailed economic analysis that outlines the estimated

ann~iul

cost

for each item under thc current regulatory franeworli and compares it to the

estimalcd ~liiii~ial

costs to be incurred under the proposed regulations. The differcnce is

exprcsscd as cither a decrease (cost benefit to owners and operators) or a increase (cost

incre;~sc to owncrs and operators). Any additional ass~~mptions

over those o~ttlined above

arc prcscntced in the detailed analysis.

810.104(a)(l)

Updating Federal Regulations Incorporated by Reference.

Non-substait~ve and no economic effect.

Proposcd Amendment 2

81 0.104(a)(l)

Updating Federal Regulations Incorporated by Reference

Non-substantive and no economlc cffect

810.104(a)(l)

Updating Federal Guidance Incorporated by Reference

Non-substantive and no ecoiloinic effect

811.309(g)(l)

---

Leachate Monitoring List

The list of leachate nionitoring parameters has been codified in the regulatio~ls.

Tile new monitoring list is similar to the current list sampled once per year and

typically

I-eferenced as the L1

L2 list in MSWLF facility operating pernlits.

The L1 list referenced in permits has been deleted. The L1 list is cu?-rently

sampled 3 tirnes per year. The proposed list in 81 1 appendix C will be sampled

semi-annually. In summary,

leachate monitoring is proposed to be changed fiom

q~~arterly

to semi-aunual during the initial 2 years of monitoring. The sampling

iiequency is urlchanged during the life of the site subsequent to the first 2 years.

Tlie list of

inonitoring parameters has been expanded to include 202 constituents

during evevy sainpling event.

The current

require~llent is to sample the L1 list quarterly for 2 years and semi-

annual for the subsequent

38 years. Since the initial 2 years of sa~npling only

adds

2 additional sampling events during the facility lifeti~ne they are not included

this analysis.

Electronic Filing, Received, Clerk's Office, February 15, 2007

If the 1-1 list cost lo collect a sample is $200 and the cost for analysis is $350 per

location,

the annual cost is approximately $2,200.

Y

S550

1 per yeai-

$2,200

If the

LI and L2 list cost to collect a slunple is $250 and the cost for analysis is

$1.000, the minimum annual cost is $5,000 for the life of the facility.

X

$1,250 X 1 quarter

$5,000

The current estimated annual cost for leachate monitoring is $7,200.

'T11e new requirement is lo monitor the appendix C list semi-annually for the 40

year life

of tile facility.

If the appendix

C list (similai- to L1

12) cost to collect a slunple is $250 and the

cost for analysis is $1,000, the miniinuin annual cost is $10,000 for the life of the

facility.

4 X

1,250 X 2 quarters

$10,000

The proposed estimated annual leachate monitoring is $10,000

ECONOMIC

EFFECT

individual annual cost illcrease

S2,800

industry a~inual cost increase

$142,000

Proposed Amendment 5

81 1.309(g)(2)(G)

List of Monitoring Parameters

See analysis in proposed arnendinent

Pro1,osed Ameildment 6.

811.309(g)(3)(D)

List of Monitoring Parameters

Sce analysis in proposed amendment

Proposed A~nendmenl 7.

81 1.309(g)(4)

Leachate Mo~iitoring Location Network

See analys~s in proposed amendment 5

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81 1.309(~)(5)

Frequency of Leachate Monitoring

Sci. ,~naiysis 117 proposed amendment 5

I'rcxx>sccl Amendment 9.

81 1.hppendix

List of Leachate Monitoring Parameters

Scc analysis in proposed ainelldlnent 5

81 1.315(e)(l)(G)(i)

Groundwater standard

No quant~fiable ecc~iiomic effect.

1 1.

c_rouosed Amendment 11

811.315(e)(l)(G)(ii) -Groundwater standard

?doll-substant~vc and no ecollolnic effect

Proposed

Amendment 12.

81 1.318(c)((i)(B)

Depth of Well Measurements

For wells which contain dedicated sampling pumps, eliminating the requirement

to measure

tile total depth of the monitoring at each sampliilg event will certainly

reduce the amount of man-hours required to collect samples at each individual

well. It is

not a tangible cost that can be easily quantified. In addition, the value

cnsuring that the integrity of the sample collected from the well is protected by

11ot disturbing the well and reducing the risk of introducing colltaminants is

difficult to quantify. However, these costs may be balanced by the increased cost

to install

and maintain dedicated sampling pump systems.

T11c primary driver of this proposal is improved data quality. The NSWMA is of

the opinion that there is a modest positive economic effect

by reducing the

frequency

of total well depth measurements. The actual amount is not easily

quantifiable and has

not beell estiluated in this study.

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Nail-substatitivc ant1 no economic effect

14.

~~upo>scoj

Aniend~mlt 14.

81 1.318(e)(6)(D)

Temperature

Non-iubsta~it~ve

and no ecoiloinlc effect

15.

Proposed Ancndment 15.

81 1.318(e)(6)(E) -Specific Conductance

Non-s~tbstantive and no economic eSSect.

81 1.318(e)(7)

Well Depth

See analysis in proposed amendment 12

Proposed Amendment 17

81 1.3 18(e)(8)

Additional Monitoring Well Requirements for MSWLF

Non-substantive and no econo~llic effect.

Proposed Amendment 18.

81 1.319(a)(2)(A)(ii)

Public or Food Processing Water Supply Standard

Th~s sect~on has been deleted The actual economic efSect is summarlzed in

proposed a~llendrnent 19

PI-oposed Amendment 19.

81 1.319(a)(2)(A)(ii)

Monitored Constituents (New Section)

A specific iis~ of indicator paralueters for monitoring groundwater has been

codified in

this proposed ainendment. The current requirement is to specify an

iiidicatol- list referenced as the G1 list in the facility operating perinit. The GI list

is a indicator list

rhat is sampled quarterly throughout the life of a facility. This

proposal

alllends the G1 list by deleting certain constituents and adding others.

Electronic Filing, Received, Clerk's Office, February 15, 2007

Altho~igli thcl-c is a slight increase in cost, the net change in economic cost of

amending the indicatoi- list is insignificant.

Therefore no economic effect is

attributed to this proposed change.

81 1.319(a)(3)(.l)(i)

Monitored Organic Constituents (New Section)

Thc Pctitioiier proposes, with the concurrence of the Illinois EPA, to add a

specific list

oi' orga~iic chemicals that must be monitored on a semi-cmi~~~al

basis.

('urrently, organic monitoring is perforn~ed once every yeas and is specified in the

fkcility operating pennit as the

list. This proposed amendment codifies the

current

list anti increases the monitoring frequency to semi-annually. The

rcvised list does eliminate certain, less mobile, semi-volatile, pesticidelherbicides,

and P<:Ws tllo~igh incorporates phenols and oil and grease. Altho~igh the language

in this section is specific to the monitoring of organic chemicals the

list also

contains a list of inorganic constituents which are monitored without filtering of

the sample which is referred to as total value.

Since

tlie requirement for

monitoring total inorganics has been removed this analysis will also consider the

iinpact of removing total inorganics, semi-volatile organics, pesticideslherbicides,

and I'CB's.

The current reqriiremcnt is to sample the

list ailnually for the lifetiiiie of

tlie facility. The requireine~lt to sample the

list is essentially unchanged.

the cost for collect~ng a sample for the

list is

$250

aild the cost for analys~s

is approx~matcly

$1000

The a~~nual

cost 1s

$25,000

The estimated cost for the current annual G1

G2 sampling is $25,000

The proposed sampling requirements are for the

list and volatile organic

clicniicals semi-annually for the lifetime of the facility. The

list is no longer

required. The only new cost is for volatile organic chemical analysis.

lf the cost to collect a sample is

$200

and the cost for analysls is

$175

The

annual cost

15,000

The estimated cost for the proposed semi-annual sampling requirement is

$15,000

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E('0NOMIC EFFECT

1iitlividu;~i ;~nntial cost ctecrease

$10,000

Industry annual cost decrease

$510,000

811.319(a)(3)(B)

Monitoring Frequency

Non-substantive and no economic effect

22.

Proposed Amendment 22.

81 1.3 19(a)(3)(C)

Organic Monitoring Frequency

See analysis in proposed amendment 20

23.

Proposcd Amendment 23

81 1.319(a)(4)(A)(i)

Confirmation Monitoring

The proposed amendment provides the opportunity for a facility to reduce their

respective false positive rate from current high levels

(i.e.,

5%)

approximately

consistent with USEPA guidance. This will reduce the amount

of collfirrnalion sample events and the potential for unllecessarily triggering an

assessment monitoring requirement.

The effect of the proposed c11a11ge will be a

potential reduction in the number of

assessmellt monitoring events. The actual

economic

eSSect of this specific proposed change is difficult to quantify. An

analysis of the effect that this overall

rulemaking's potential to reduce

unnecessary assessment

inonitoring events is presented in the analysis under

proposed amendment

36.

24.

Proposed Amendment 24

811.319(a)(4)(B)(i)

Verification Samples

This proposed amendment will allow for a eo~nplete review of the laboratory

analysis and verify that any confirmation of

a "Monitored Increase" is not a

laboratory or sampling artifact, It will also reduce the amount of samples

collected and

an:lalyzcd by allowing the verification sampliiig to be conducted

during the next quarterly sampling event.

In many instances due to the high false

positive rate under the existing regulations, MSWLF facilities are monitoring 8

times per year during the verification process i-ather than the required 4 times per

year.

'I'liis creates problems for ~naintaining sample independence which is an

iinpo~-tax~t

statistical basis.

Electronic Filing, Received, Clerk's Office, February 15, 2007

ihc actual cconomic effect of the proposed change will vary significailtly from

site to site and is not directly quantifiable. However, an estimate of the overall

cTl'cct is prcsmted as a rough approximation.

A typical thcility may be required to perform verification sampling on at least one

pi-ametcr in 50% of the wells for every quarterly sampling event. If the cost is

S200 to collect the sample and $50 to analyze

thc sample, the annual cost is

$10,000.

10 wells X

S250

$10,000

ECONOMlC EFFECT

li~d~vidual

annudl cost decrease

$10,000

Industry annual cost decrease

$510,000

Proposcd Amcndm-

81 1.319(a)(4)(B)(iii)

Notice of Confirmation and Source Determination

No economic effect.

Proposcd Amendment

26.

811.319(b)(2)

Assessment Monitoring, Timing of Plan Filing

No econoniic effect.

P3xoposed Amendment

811.319(b)(S)(A)

Assessment Monitoring, Additional Constituents

No economic effect.

28.

groposed Amendment 28

811.319(b)(5)(D)

Assessment Monitoring, Timing

Although the proposed language may infer some economic benefit it is not easily

quantifiable since the actual list of constituents to be monitored will vary

from

Facility to facility. Therefore no quantifiable economic impact of the proposed

change is identified

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Proposed Ainetldment 29.

81 1.31Y(b)(S)(E)

Assessment Monitorir~g, Constituents

No econi)mic effect.

30.

proposeti Aine~cinient 30.

81 1.319(b)(5)(G)

Assessment Monitoring, Constituents

No ccoi~omic effect

P1-oposec1 Amendment 3 1.

811.319(d)(l)(A)

Assessment Monitoring, Capitalization Correction.

Non-substantive and no economic effect.

32.

Proposed An~end~nent

32.

81 1.319(d)(3)(A)

Assessmer~t Monitoring, Reference Clarification

hon-si~bstantive and no economlc effect

33.

Proposed Ailleildment 33

811.320(a)(3)(B)

Groundwater Quality Standards, Board Established

Startdards

No econoliilc effect

34.

Prot~osed Amendment 34.

811.320(b)(2)

Adjusted Groundwater Quality Standards

No economic effect.

35.

Proposed Amendment 35.

1.320(b)(4)

Adjusted Groundwater Quality Standards

KO economic effect.

Proposed Amendment 36.

811.320(d)(l)

Establishment of Groundwater Background Concer~tration

Electronic Filing, Received, Clerk's Office, February 15, 2007

The proposeed language of this section as well as the proposed changes in other

scctioris of this I-ulemaking are designed to reduce unnecessary assessment

monitoring

triggered by an excessively high false positive rate during statistical

i-cvic\v of gro~~nd\vatcr

monitoring data. The net affect will be to reduce the

numhcr of asscsslilent nionitoring events which are not nccessary. Although the

prescntcd

cco~?o~nic

effect

this

section,

a reduction

the estimated

in the number

reduction

assessment

monitorini!

nlonitoring

olans

plans

will

result ftom the language changes proposed througho~~t

this rulemaking.

The actual cost of an assessment can vary depending on the event that triggered

the require~~ient

to develop an assessrnellt monitoring p1a11. Some plans require

tl~e installation of additional wells. Since this is not required for every event this

analysis simply estimates the cost for preparing an assessment monitoring pian

that contains the necessary iiifo~lnation to be reviewed by the Illinois

Environmental Protection Agency as a "Significant

Modificaiion" to the facility

operating

permit.

The estmiated cost to prepare ail assessment mon~toring plan IS typically $25,000

The current rules

tr~gger an assessment at least semi-annually

Therefore the current annual cost is estimated at $25,000

It is ant~c~pated

that the proposed changes will reduce the amount of assessments

hy 50%

Therefore the proposed annual cost is estimated at $25,000

ECONOMIC EFFECT

I~icl~vidual

annual cost decrease

$25,000

Industry annual cost decrease

$1,275,000

37.

Proposed Amendment 37

811.320(d)(2)

Adjustment to Background Concentrations

See aiialysis in proposed amendiilent 36

(50534303 i ?/i5~2007 'I'iiW KAV)

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38.

F'rijl~scd hrnc~m!~i~~x.

81 1.320(d)(3)

Background Concentrations

Scc anal!sis in proposed ameiidment 36

Proiloscd Amendment 39.

81 1.320(d)(4)

Background Concentrations, Monitoring Wells

Noii-substa~~ti.ve

and no ecouomic effect

40.

Proposed

Amen&nent 40.

81 1.320(d)(5)

Background Concentrations, Non-Hydraulically Upgradient

Non-substantive and no economic effect.

Proyosed Aniendmc&41.

81 1.320(d)(6)

Background Concentrations, Atternatives

Non-substantive and no ecollomic effect.

42.

Prouosed Arncndnicnt 42.

81 1.320(e)(l)

Statistical Analysis of Groundwater Data

No economrc effect.

Proposed

Amendment 43

81 1.320(e)(3)

Use of the Practical Quantification Limit ("PQL")

No cconomic effect

44 Proposed

Amendmerit 44

81 1.320(e)(3)(A)

IJse of PQL's

ecoiiorr~~c

cffect

45.

Proposed.Amendnlent 45.

811.320(e)(3)(8)

Alternative Groundwater Analysis Procedures

No cconomic erfect.

Electronic Filing, Received, Clerk's Office, February 15, 2007

l'~c)po!,eci 411icndmcnt 40.

81 1.320(e)(3)(C)

Altertlative Groundwater Analysis Procedures

1.320(e)(4)

Specific Normal Theory Statistical Tests

No economic effect

Proposed Amendment 48

811.320(e)(5)

No~~parametric

Statistical Tests

No economic effect

81 1.320(e)(6)

Other Available Statistical Tests

No economic effect.

111 conclusion, based on the above analysis of the potential

eco~loinic effect upon

MSWLF owners and operators the proposed rulemaking has ail estimated a~lnual cost

saviiigs of 542,200 for each facility subject to the i-t~les. The estimated annual cost

savings to

the industry for the 51 active MSWLF operating in the state of Illinois is

$2,153,000.

Thanit you

1511834303

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Electronic Filing, Received, Clerk's Office, February 15, 2007

BEFORE THE ILI,INOIS POLLUTION CONTROL BOARD

In the

Matter

of:

)

I'TZOPOSED AMf:NDMENTS TO

SOLID WASTE DISPOSAI,: GENERAL PROVISIONS

)

R 07

008

35 Ill. Adm. Code 810; and,

(Rulemaking

Land)

STANDARDS FOR

NEW SOLlD WASTE LANDFILLS

)

LAKDFILLS

Ill. Adm. Code 811.

ERRATA SHEET #3

NOW COMES Proponent, the National Solid Wastes Managemeilt Assocratioli

Midwest Regloll ("NSWMA") by and through its attorneys, Sorl~ng, Korthrup, Haniia, Cullen

6(

Cochran, Lld

Charles J Northrup, of counsel, and hereby provides an Ei-rata Sheet

113

wlth

respect to a portion of the proposed rule amendments.

On July 27, 2006, the NSWMA liled its "Proposal to Amend Certain Pollutioii

Coritrol Board Regulations Related to Solid Waste Management Facilities." These proposed

ainencirneiits relatcd to certain requirements at

I11.Ad1n. Code 810 and 811. 011 August 17,

2006, the Board accepted the Proposal for hearing.

On Jan~luary 16, 2007 the NSWMA filed its "Supplemental Information and Errata

Sheet

On Jai~uary

25,

2007 the NSWMA filed its "Errata Sheet

#2."

Electronic Filing, Received, Clerk's Office, February 15, 2007

.1a11~1:ir>g

20. 2007, the Board held its first hearing in this matter. During that

heciriilg,

iiurnbcr of comments were made concerning certain aspects of thc proposeci

ai~iendmciits tirat iiiight he renlcdied by minor language changes. None of the comments address

the substance of'thc proposed rule. These commeIlts are addressed and rrlcorporated into new

language set out

m

the attached "Errata Sheet 3."

Respectfully submitted,

NATIONAL SOLID WASTES MANAGEMENT

ASSOCIATION

By:

Soi-ling, Norlhrup, Na~i~lna,

Cullen

Cochran, Ltd.

Cl1aries J. Northrup, of Counsel

Suite 800 Illii~ois Building

P.O. Box

5

131

Springfield, 11,62705

Telephone: 21 7.544.1 144

Fax:

217.522.31 73

E-Mai

~;~~>~j~~~>(<~i!i.,Iji~&~>_i~~~

Electronic Filing, Received, Clerk's Office, February 15, 2007

ERRATA SHEET #3

Proposed (Revised) Section 81 1.319(a)(2)

(New subsections (A)(iii) and (iv)

Criteria fbr Choosing Co~istitueilts to he Monitored

The

opcrator shall monitor each well for constitueills that will provide a

means for detecting groundwater contamination. Constituents shall be

chosen

ror monitoring if they meet the followi~lg requirements:

The constituent appears in, or is expected to be in, the leachate:

and

n',is

cogt_a_i=ned

w&kn

foS10wi11~ list of constit~~e~~ts.

LThis

&ke,~~ainimum

list ibr .MSWLFS.

ivi

Any facility acce-ptine more than

50%

by volun~e

11013-municipal

must determine additional indicator Daralneters based

upon leachate

characteristic and waste conk~

Electronic Filing, Received, Clerk's Office, February 15, 2007

Proposed (New) section 811.320(b)(l)

(new regulatory references)

Just~ficat~on

for Adjusted Grouildwaier Qual~ty Standards

An operator may petition the Board for an adjusted groundwater

quality standard in accordance with the procedures specified in

Section

28.1 of the Aci and 35 ill. Adm. Code 104.400 et. seq.

Electronic Filing, Received, Clerk's Office, February 15, 2007

SERVICE LIST

iilectronic;iily filed witli:

Ms. Dorothy M. Gunn

Pollution Control Board

James R. Thompson

Centei-

100 West Randolph St., Suite 11-500

Chicago, IL

60601

And the rollowlllg served by U.S. Mail:

Mr. Matt Dunn

Ms. Kim Geving

Enviromnental Bureau Chief

Assistant Counsel

Office

of the Attorney General

Illinois

E~~vironmental

Protection Agency

Jaines R. Tlionipson Center.

1021 North Grand Ave. E.

100 Wcst Ranclolph St., 121h Fl.

P. 0. Box 19276

('hicago, IL 60601

Springfield, IL 62794-9276

Ms. Brenda Carter, Project Manager

Ms. Claire

B. Eberle, Deputy Director

lllii~ois Envii-ol~mental Regulatory Group

Joint Committee on

Administrative Rules

3 150 Roland Avc.

Wm. G. Strattoll Office Bldg., Room 700

Springfield,

It. 62703

Springfield, IL 62706-4700

Mr. Roger I-Iuebner, Gen. Couiisel

Ms. Linda Dirlisen Brand

Illiiiois Municipal League

Advocacy Specialist

500

E. Capitol

Dept. of Commerce

Economic

P.O. Box 51 80

Opporluliity

Springfield, 1L 62705

620 East Adams St., Fifth F1.

Springfield, IL 62701

Mr.

Williani Richardson

Mr. Jack

Darin

C:IiieT Legal Counsel

Sierra Club

Ill.

Dept. of Natural Resources

200 N. Michizan, #505

Onc Natural Resources Way

Chicago, IL 60601

Springfield, IL

62702-1271

Mr Wllllanl Schubert

Waste Managemeilt, Inc

720 Butterficld Rd

Lombard,

IL 60565

Mr.

Tlrn Fox, Hearing Officer

James R. Thompson Center

100

W. Raiidolph

Suite 11-500

Ch~cago, IL 60601

Ms.

Kathy A~idvia

Ms. Joyce Blumensliinc

Aii~erican Rotto111 Conservancy

Heart of Illinois Group

Post Office Box 4242

2419

E. Reservoir

I'airview I-ieigl~ts, IL 62208

Peoria, 1L 61614

'50534234 1 2i14i2007

C.iN BLI'J

Pt.inlcd

iiii

Recycled i'nppr

Electronic Filing, Received, Clerk's Office, February 15, 2007